Ethics 

Our Code of Ethics

Upholding honesty and integrity at every level is critical to our success. We each have a responsibility to act professionally, understand the Company Code of Ethics and Business Conduct, policies and applicable laws, promptly report concerns and share Patterson-UTI’s commitment of mutual respect by demonstrating courtesy and civility.

Patterson-UTI policy prohibits bribery, including offering, giving, receiving, or agreeing to a request for or offer of a bribe. This prohibition applies whether the bribe or offer of a bribe is being made by or to a Patterson-UTI employee or someone outside the Company on behalf of the employee or the Company.

It is our policy to comply with all relevant anticorruption and anti-bribery laws and rules, including, but not limited to, the FCPA, the U.K. Bribery Act and any laws enacted pursuant to the OECD Convention. Violation of our policy subjects personnel to disciplinary action, up to and including termination.

Responsibility and Accountability

Our management evaluates risk in our business and to our Company to ensure that plans are in place to minimize and manage risks to our Company, to customers and to individuals. Our Board of Directors evaluates its role in risk oversight on an ongoing basis.

Recognizing the serious risks posed by corruption in international business transactions, and the seriousness with which governments around the world are enforcing anti-bribery laws, as directed by the Board of Directors, we implement policies and procedures to prevent the Company and its employees from being involved in any bribery and corruption. Involvement in corrupt business activities, and sometimes only the perception of such involvement, can have serious consequences for Patterson-UTI, its employees and business partners.

We are committed to the continuous improvement of our anticorruption and anti-bribery compliance efforts. We periodically monitor and conduct testing and review of our anticorruption and anti-bribery policies and related business processes to assess their suitability, adequacy and effectiveness. Patterson-UTI addresses weaknesses and implements improvements as appropriate. We issue, implement and revise all policies and procedures necessary to effectively implement these policies.

Through our Vendor Guidelines, we also set forth expectations of our vendors, suppliers and their subcontractors, and these guidelines are intended to complement our Code of Business Conduct and Ethics.

Our related formal policies include:

• Global Anticorruption Policy
• Gifts and Entertainment for Government Officials
• International Due Diligence
• Prohibition on Corruption
• Antitrust Compliance
• Conflicts of Interest, Including Gifts and Entertainment
• Vendor Guidelines

 

We understand that corruption risks can be introduced through our supply chain, particularly in connection with suppliers operating in high-risk locations or those functions that may have a reputation for questionable business practices. Our procurement practices are conducted in a transparent manner that ensures services are procured in a fair, economical and open process. Whenever possible, our suppliers and service providers are selected competitively and on the basis of clear and uniform criteria. We launched an updated global anticorruption training required annually for certain employees based on duties of their job.

Patterson-UTI’s Code of Business Conduct and Ethics outlines the standards and principles that all employees, officers and directors must follow when working with co-workers, vendors, customers or other third parties. The policy addresses conflicts of interest, confidentiality, fair dealing with others, proper use of Company assets, compliance with laws (including anti-money laundering laws, anti-trust laws, anti-boycott regulations, and global trade laws), insider trading, keeping of books and records, zero tolerance for discrimination and harassment in the work environment, as well as reporting of violations.

Our dedicated Global Anticorruption Policy prohibits all forms of bribery, addresses training and provides the requirements for careful due diligence of potential partners and intermediaries. Patterson-UTI does not tolerate any retaliation against an employee who in good faith asks questions, makes a report of actions that may be inconsistent with our Code of Business Conduct and Ethics, policies or laws or regulations or who assists in an investigation of suspected wrongdoing. At

Patterson-UTI, ethical behavior means always acting with integrity and doing the right thing. That means using good judgment and following applicable laws. We strive to treat everyone with fairness and respect. We do so not because it is the law, but because it is the right thing to do.

Our code applies to all directors, officers and employees of Patterson-UTI and its affiliates. Business partners are an extension of Patterson-UTI and can have an impact on our good name. For this reason, they are expected to act consistently with our code. Each of us plays a critical role in safeguarding the reputation of the Company.

All Patterson-UTI employees are responsible for speaking up anytime they become aware of potential violation of our code, policies or laws. We encourage a supportive environment where people are free to ask questions and raise concerns. We listen and respond. We strive for an atmosphere based on mutual respect and free of discrimination, harassment and retaliation..

Political Contributions

We have a policy prohibiting the contribution of Company funds to political parties or organizations or to candidates for any public office or to influence the general public, or segments thereof, with respect to public elections or referenda.

Industry Initiatives

We participate in certain trade organizations, such as the IADC and the EWTC, with purposes that include enhancement of the public image of and continued education about the industry, collaboration on issues that affect the industry and the development of industry best practices and standards, as well as development of industry talent. We have also held leadership positions within the IADC and the EWTC.

We are a member of various subcommittees of both organizations which regularly meet to discuss practices in the contract drilling, completion services and other related industries. Many of the trade organizations also engage in legislative or political activity related to matters that affect the industry as a whole and not a specific company. We, as one of many members in various trade associations, do not direct the legislative activities of any trade organization of which we are a member.

Antibribery Training

Our anticorruption training program includes antibribery training for all employees with responsibilities that include finance, accounting, keeping of Patterson-UTI books and records, international markets and international travel. All employees with international responsibilities acting on Patterson-UTI’s behalf or interacting with government officials on a regular basis or those with significant managerial responsibilities participate in more specific antibribery training at least annually. The Company’s Anticorruption Policy is available on its external website.

Less than 0.05% of our consolidated worldwide 2023 revenue was generated from the countries identified by Transparency International as having the 20 lowest rankings in its 2023 Corruption Perception Index.

We encourage employees to report a concern or ask a question through a supervisor, manager, HR representative or the anonymous SHARP Hotline and to speak up if they think something is wrong. Our anonymous SHARP Hotline is administered by a third party. We view the SHARP Hotline as a key risk management tool for the Company, as the anonymous reporting provided by this hotline helps to ensure that employee concerns are investigated and addressed as promptly as possible.

SHARP: Secure Hotline For Asking and Reporting at Patterson-UTI

The SHARP Hotline is available 24/7, online or by phone, for employees and others to report concerns, anonymously if preferred. Please see our SHARP page for more information about our secure reporting hotline.